Privacy Policy
Last updated: April 2024
At AAMA.io, a platform developed by Uxqode Pte Ltd, we are committed to protecting and respecting your privacy in accordance with Singapore's Personal Data Protection Act (PDPA). This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our platform or services. As a technology platform that enables fund managers to launch and manage funds, we process data on behalf of these fund managers and their investors.
1. Introduction
This Privacy Policy applies to all personal data that you may provide to AAMA.io and information we collect about you in relation to your use of our platform. By accessing our platform or using our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal data as described herein.
2. Our Role as a Data Processor and Controller
AAMA.io acts in two capacities with respect to personal data:
- As a Data Controller: For data we collect directly from you for platform access, account creation, and our direct relationship with you
- As a Data Processor: For data we process on behalf of fund managers who use our platform to provide services to their investors
This Privacy Policy primarily addresses our practices as a data controller. When we process data on behalf of fund managers, we do so according to their instructions and their own privacy policies may also apply to the processing of your data.
3. Personal Data We Collect
We may collect the following categories of personal data:
- Identity Information: Name, NRIC/FIN/Passport number, date of birth, nationality, signature
- Contact Information: Email address, telephone number, mailing address, business address
- Financial Information: Bank account details, payment card information, transaction history, investment preferences, fund transfers
- Professional Information: Job title, employer, professional qualifications, accredited investor status
- Technical Information: IP address, login credentials, browser type, device information
- Usage Data: Information about how you use our website, platform, and services
- Marketing Preferences: Your preferences in receiving marketing communications
- Communication Records: Records of communications between you and AAMA.io
4. Purposes for Collection, Use and Disclosure
We collect, use, and disclose your personal data for the following purposes:
- To establish and manage your account on our platform
- To provide and administer our platform services
- To facilitate transactions and investments between fund managers and investors
- To fulfill our contractual obligations to you and to fund managers
- To comply with legal and regulatory obligations including KYC and AML requirements
- To support fund managers in verifying investor identities and conducting background checks
- To respond to your inquiries and provide customer support
- To improve and personalize our platform and services
- To communicate important notices and updates to you
- To protect our legal rights and interests
- To detect and prevent fraud and security breaches
- To conduct market research and data analytics to improve our platform
5. Consent
By providing your personal data to AAMA.io, you consent to the collection, use, and disclosure of your personal data for the purposes set out in this Privacy Policy. You may withdraw your consent at any time by contacting us using the details provided below. However, please note that withdrawal of consent may affect our ability to provide platform services to you. We will notify you of the consequences of your withdrawal of consent.
6. Notification Obligation
We will notify you of the purposes for which we intend to collect, use, or disclose your personal data before such collection, use, or disclosure, unless applicable exceptions under the PDPA apply. If we intend to use or disclose your personal data for a new purpose, we will notify you and obtain your consent before doing so.
7. Disclosure of Personal Data
We may disclose your personal data to the following categories of recipients:
- Fund managers using our platform to provide services to their investors
- Our affiliated companies and business partners
- Third-party service providers who process data on our behalf
- Financial institutions and payment processors
- Professional advisors including lawyers, auditors, and insurers
- Regulatory authorities, government agencies, and law enforcement when required by law
- Potential buyers or investors in the event of a business transaction
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. Transfer of Personal Data Outside Singapore
We may transfer your personal data to countries or territories outside Singapore for the purposes described in this Privacy Policy. When transferring personal data outside Singapore, we will take appropriate steps to ensure that the recipient provides a standard of protection to your personal data comparable to the protection under the PDPA, such as entering into contractual agreements that include appropriate safeguards.
9. Data Security
We have implemented appropriate security measures to protect your personal data against unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. We regularly review and update these measures to maintain the integrity and confidentiality of your personal data. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.
10. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. We will securely dispose of or anonymize personal data which we no longer need for any purpose. For data we process on behalf of fund managers, retention periods will be determined by their requirements and applicable regulations.
11. Access and Correction
Under the PDPA, you have the right to request access to and correction of your personal data held by us. If you wish to make such a request, please contact us using the details provided below. We may charge a reasonable fee for processing your access request. We will respond to your request as soon as reasonably possible. If we are unable to provide access or make a correction within 30 days, we will inform you of the time frame within which we can respond. For personal data that we process on behalf of fund managers, we may direct your request to the relevant fund manager.
12. Do Not Call (DNC) Registry
In compliance with Singapore's DNC Registry provisions, we will not send marketing messages to Singapore telephone numbers which are registered with the DNC Registry, unless we have received clear and unambiguous consent from you or we are permitted to do so under the PDPA. If you wish to opt out of receiving marketing messages from us, you can register your telephone number with the DNC Registry or contact us directly.
13. Cookies and Tracking Technologies
Our platform uses cookies and similar tracking technologies to enhance your browsing experience and collect information about how you use our platform. You can manage your cookie preferences through your browser settings. For more information about cookies and how we use them, please refer to our Cookie Policy.
14. Third-Party Links
Our platform may contain links to third-party websites and services that are not owned or controlled by Uxqode Pte Ltd or AAMA.io. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our platform. The updated Privacy Policy will take effect from the date stated at the top of the policy. We encourage you to review this Privacy Policy periodically.
16. Data Protection Officer
We have appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and addressing any questions or concerns. If you have any inquiries, requests, or complaints regarding your personal data or this Privacy Policy, please contact our DPO at contact@aama.io.
17. Platform Users and Fund Managers
If you are a fund manager using our platform, you are responsible for ensuring that your collection, use, and disclosure of your investors' personal data comply with the PDPA and other applicable laws. You should provide your own privacy policy to your investors and ensure you have the necessary consents for us to process their data on your behalf. We will process such data in accordance with our agreement with you and your instructions.
18. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
Uxqode Pte Ltd (provider of AAMA.io)
Email: contact@aama.io
Address: Singapore